December 30, 2019

Jeff Carberry
Chief Financial Officer
STAMPS.COM INC
1990 E. Grand Avenue
El Segundo, California 90245

       Re: STAMPS.COM INC
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed March 1, 2019
           File No. 000-26427

Dear Mr. Carberry:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2018

Notes to Consolidated Financial Statements
Revenue Recognition, page F-13

1.    You disclose customers pay a monthly fee based on a subscription plan,
which may be
      waived or refunded for certain customers. We also note from your website
that customers
      are offered free postage and coupons for reduced postage. Please tell us
and disclose
      pursuant to ASC 606-10-50-20 how you account for the noted items. Also,
explain to us
      your consideration of ASC 606-10-32 in your accounting.
 Jeff Carberry
STAMPS.COM INC
December 30, 2019
Page 2



       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Theresa Brillant at 202-551-3307 or Doug Jones at
202-551-3309 with
any questions.



FirstName LastNameJeff Carberry                           Sincerely,
Comapany NameSTAMPS.COM INC
                                                          Division of
Corporation Finance
December 30, 2019 Page 2                                  Office of Trade &
Services
FirstName LastName